California, United States of America
The following excerpt is from Kashani v. Wilshire House Ass'n, B296976 (Cal. App. 2020):
[Citation.] . . . Because expert witness fees are not incidental to the judgment, the propriety of a postjudgment award of expert witness fees cannot be reviewed on an appeal from the judgment.' [Citation.]" (Id. at p. 1317, quoting Fish v. Guevara (1993) 12 Cal.App.4th 142, 148.)
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